As Switzerland is not a member of the EU or the EEA, financial institutions based in Switzerland do not automatically have a “passport” to conduct activities in the EU. As there is presently no general cross-border exemption for Swiss-based firms, such firms are, in principle, required to follow the ordinary approval procedure for the establishment of a branch or subsidiary in the EU. Certain simplifications regarding access to the EEA particularly apply under the Alternative Investment Fund Managers Directive (AIFMD). However, automatic access is not guaranteed. Access of Swiss financial service providers to the EU/EEA in the future will, to a large extent, depend on whether Swiss financial regulation, as it is currently being reformed, will be regarded as equivalent to EU regulation.

For the offering and intermediation of insurance contracts, passporting rights apply between Switzerland and Liechtenstein based on a respective international treaty. An additional treaty was agreed but has not been ratified yet between Switzerland and the UK.